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#2267175 - 03/04/22 02:55 AM Fees on LE
theloanbug Offline
Platinum Poster
Joined: Sep 2005
Posts: 720
Do you charge fees on LE to your customers that you know from beginning that bank never will never require?

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TRID - TILA/RESPA Integrated Disclosures Rule
#2267177 - 03/04/22 12:21 PM Re: Fees on LE theloanbug
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 79,633
Galveston, TX
If you are, you are in violation, as your LEs are not being issued in good faith.
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#2267180 - 03/04/22 01:34 PM Re: Fees on LE theloanbug
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,839
Bloomington, IN
That's call fee padding and as Randy stated that is a blatant and willful violation of the regulatory good faith standard.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2267217 - 03/04/22 10:59 PM Re: Fees on LE Dan Persfull
theloanbug Offline
Platinum Poster
Joined: Sep 2005
Posts: 720
That is how I see it. Just making sure. Thanks for your help.

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#2267314 - 03/08/22 08:25 PM Re: Fees on LE theloanbug
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,684
Cape Cod
Not only could it result in a citation for Regulation Z and Truth in Lending violations, but also it could require a full refund of all closing costs to the borrower. It could also raise questions about the bank's overall compliance program.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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